Filed: Oct. 21, 2014
Latest Update: Oct. 21, 2014
Summary: STIPULATION AND ORDER RE: PLAINTIFF'S DEPOSITIONS OF WITNESSES PURSUANT TO F.R.CIV.P. 30(b)(6) WILLIAM B. SHUBB, District Judge. ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE as follows: This case was filed on March 3, 2014. (Doc. 2). Defendants Answered on April 14, 2014 (Doc. 8). The Pretrial Scheduling Order was entered on May 27, 2014. (Doc. 14). The Order to Amend Scheduling Order to Continue Discovery/Motion Deadlines, Pretrial Conference, and Trial was enter
Summary: STIPULATION AND ORDER RE: PLAINTIFF'S DEPOSITIONS OF WITNESSES PURSUANT TO F.R.CIV.P. 30(b)(6) WILLIAM B. SHUBB, District Judge. ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE as follows: This case was filed on March 3, 2014. (Doc. 2). Defendants Answered on April 14, 2014 (Doc. 8). The Pretrial Scheduling Order was entered on May 27, 2014. (Doc. 14). The Order to Amend Scheduling Order to Continue Discovery/Motion Deadlines, Pretrial Conference, and Trial was entere..
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STIPULATION AND ORDER RE: PLAINTIFF'S DEPOSITIONS OF WITNESSES PURSUANT TO F.R.CIV.P. 30(b)(6)
WILLIAM B. SHUBB, District Judge.
ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE as follows:
This case was filed on March 3, 2014. (Doc. 2). Defendants Answered on April 14, 2014 (Doc. 8). The Pretrial Scheduling Order was entered on May 27, 2014. (Doc. 14). The Order to Amend Scheduling Order to Continue Discovery/Motion Deadlines, Pretrial Conference, and Trial was entered on August 27, 2014 (Doc. 26). Currently, discovery is scheduled to close on (and all discovery motions must be heard by) November 7, 2014. Trial is scheduled for for March 24, 2015. (Doc. 14).
On September 30, 2014, Plaintiff noticed for October 14, 2014 the following depositions pursuant to Federal Rule of Civil Procedure 30(b)(6):
1. The person most knowledgeable ("PMK") on behalf of the California Highway Patrol concerning the training, policies, and procedures, from three years preceding the incident described in the First Amended Complaint to the present, related to the Mobile Video/Audio Recording System (MVARS);
2. The PMK on behalf of the California Highway Patrol concerning the training, policies, and procedures, from three years preceding the incident described in the First Amended Complaint to the present, for handling persons with disabilities;
3. The PMK on behalf of the California Highway Patrol concerning the Master Voice Tape Audio Logger, and its alleged malfunction and failure to record properly on August 6, 2013; and
4. The PMK on behalf of the California Highway Patrol concerning the maintenance, loss, and/or destruction of audio and video recordings of the incident described in the First Amended Complaint.
Defendants requested that Plaintiff continue these F.R.Civ.P. 30(b)(6) depositions to allow more time to designate the PMK witnesses, to which Plaintiff agreed. On October 16, 2014, Defendants advised Plaintiff that Defendants are not able to produce the PMK witnesses before the November 7, 2014 discovery cut-off deadline.
Accordingly, the parties hereby stipulate and agree that Defendants will produce, and that Plaintiff may depose, the PMK witnesses originally scheduled for October 14, 2014 by no later than November 30, 2014.
All other dates in this matter shall remain unchanged.
ORDER
Pursuant to stipulation of the parties and good cause appearing therefore, IT IS SO ORDERED.
